Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Admission of additional ground of appeal - as the additional evidence filed by the assessee was not with a purpose or motive of bringing any fresh facts on the record, but with a limited purpose of dispelling all doubts and substantiating to the hilt that EIL was the owner of “Essar” brand prior to its settlement in the assessee trust, therefore, on the said count also no infirmity can be related to the admission of the same by the CIT(A). We, thus, in terms of our aforesaid observations not finding any infirmity in the admission of the additional evidence by the CIT(A), uphold his order to the said extent. - AT
Admission of additional ground of appeal - as the additional evidence filed by the assessee was not with a purpose or motive of bringing any fresh facts on the record, but with a limited purpose of dispelling all doubts and substantiating to the hilt that EIL was the owner of “Essar” brand prior to its settlement in the assessee trust, therefore, on the said count also no infirmity can be related to the admission of the same by the CIT(A). We, thus, in terms of our aforesaid observations not finding any infirmity in the admission of the additional evidence by the CIT(A), uphold his order to the said extent. - AT
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TaxTMI 
TaxTMI 
of 4897 
